Brazil Clarifies Treatment of Software Licensing Fees under Tax Treaty with France

The Brazilian tax authorities recently issued Ruling 6026/2016 concerning the withholding tax treatment of software licensing fees under the 1971 income and capital tax treaty with France. Under the treaty, three withholding rates are provided depending on the nature of the royalty payment: 10% for the use or right to use any copyrights, 25% for the use of trademarks, and 15% for all other type…
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